VVSG 2.0: VotingWorks's Feedback to the EAC

May 20, 2020 — Ben Adida

Today, we had the opportunity to provide feedback to the Election Assistance Commission on the Voluntary Voting Systems Guidelines (VVSG) 2.0, the upcoming federal standard for voting equipment. Here is the full text of our introductory remarks:

Commissioners, EAC Staff, and Fellow Vendors,

My name is Dr. Ben Adida. I am thankful for the opportunity to provide feedback on the VVSG 2.0 Requirements on behalf of VotingWorks.

Like you all, we are passionate about elections & democracy. We believe in the voting booth as the great equalizer - the only place where EVERY citizen has an equal voice. That’s why the Election Assistance Commission is a critical agency, because the technology we all build to support our great democracy must live up to the highest standards. Our elections must be secure, usable, and accessible.

In America, the best way we know to achieve such ambitious goals is through competition in an arena of well-crafted rules. May the best vendor win. May voters and election officials benefit from this race between vendors to build a better voting booth, a more auditable election, a truer democracy. I know: I’m preaching to the choir, but forgive me, this is my first time speaking to this esteemed group.

If we all believe in competition, why then, are we, VotingWorks, the first new voting machine vendor in more than a decade? The thrust of our feedback is that the EAC should ensure that the VVSG truly encourage and enable competition. We have 3 points:

  1. Interoperability: We commend the EAC on the Interoperability section of the Requirements. Interoperability lets a jurisdiction pick the best system for the job – the best precinct-based scanner from vendor #1 and the best accessible machine from vendor #2. The next logical step is to allow for certification of independent modules, so that a new vendor can focus entirely on the one component they can best improve. That’s real competition. That makes things better for election officials and voters.

  2. User-Centered Design & Field Testing: We also commend the EAC on the addition of user-centered design: we must design for voters and poll workers first. We urge the EAC to consider that the only true test of user-centered design is in the field, and requirements should allow for this. The requirements should be minimized for small real-world deployments, and should ratchet up as the deployments scale up.

  3. All Vendors in the Same Boat: Today, we’re the only vendor subject to the 2015 standard, while others continue to rely on a standard older than the first iPhone. This disparity turns a certification standard meant to enable competition into a mechanism for excluding new entrants. It’s not a coincidence that we’re the only new vendor in more than a decade. VVSG 2.0 should change this dynamic. All vendors should be in the same boat. Maybe then, in a couple of years, we’ll share this table with some newer vendors than us. We certainly hope so.

We have additional feedback – some of the detailed requirements are, we believe, overly prescriptive. We’ll be providing this feedback in written form over the next few weeks.

Thank you commissioners, we look forward to your questions.